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Tea Steeped in Toxics

Weak regulations and enforcement result in contaminated imported tea in U.S. market

By Nikita Naik tea that eventually finds its way to the American consumer. This includes (a synthetic , linked to cancer and uring the cooler weather months, many will turn to a cup endocrine system disruption), DDE (a metabolite of DDT, banned of hot tea as the perfect comfort drink. For the health con- in the U.S. in 1972), epoxide (a derivative of the pesti- Dscious, tea increasingly has become the preferred beverage cide heptachlor, which was banned in the U.S. for use in agricul- choice because of its many health-protective benefits. ture and as a termiticide due to its carcinogenicity and persistence in the environment),4 and (a bee-toxic neonicoti- Reason for Concern noid).5,6 Meanwhile, a 2014 U.S. Government Accountability Of- Yet, the allowance of hazardous, pesticide import residues – fice (GAO) report found that FDA now tests less than one-tenth of banned, canceled or not registered in the U.S.– raises serious one percent of all imported foods,7 which is especially problem- safety questions. One critical concern stems from a U.S. Envi- atic for tropical products such as tea, since the imported share in ronmental Protection Agency (EPA) decision in 2013 that allows the U.S. is nearly 100 percent due to a near absence of domestic a banned pesticide in tea imported from China until mid-2016. production.8 These issues underscore a number of lapses in the EPA’s decision to provide “additional time to transition to an alter- journey from tea cultivation to importation, increasing consumer native” to the highly toxic organochlorine endosulfan1 exposure to a dangerous blend of pesticides in conventional tea. puts consumers in harm’s way. However, this is only the tip of the iceberg when it comes to hazardous levels of pesticides in tea. Re- Large Market, Widespread Exposure ports from India and China find high levels of banned pesticides Tea is the most commonly consumed beverage in the world, sec- and violative residues in tea products, pointing to a lack of en- ond only to water.9 True tea, distinct from herbal tea, is sourced forcement and strong regulations on pesticide use in major tea -ex from the leaves of a plant known as Camellia sinensis and is pro- porting countries.2,3 In the U.S., the Food and Drug Administration cessed in different ways to produce varieties like white, yellow, (FDA) consistently finds high levels of illegal residues on imported green, oolong, and black tea.

Vol. 35, No. 3 Fall 2015 Pesticides and You Page 9 A quarterly publication of Beyond Pesticides Worldwide tea production has increased significantly over the increased from 14,000 tons in 1990 to 50,000 tons in 2008, yet past 10 years, growing from 3.89 million tons in 2006-2008 to 5.06 pesticide control laws have not been implemented in a way that million tons in 2013, a 30 percent increase.10 World tea exports, reflects this increase, largely due to a lack of resources, and knowl- with China, India, Kenya, and Sri Lanka as the major exporters, edge of the law on the part of regulators, enforcement, and other reached 1.77 million tons in 2013, a five percent increase over factors.18,19 The lack of strong regulations governing pesticide use 2012.11 World tea consumption continues to surge, with Russia, in countries like India and China has far reaching implications. the United Kingdom, Pakistan, and the U.S. as the leading import- ers in this market.12,13 Tea imports into the U.S. have nearly tripled Contamination of Tea from India and China over the past 15 years alone, according to the U.S. Department of In 2014, a Greenpeace India investigation, Trouble Brewing: Pesticide Agriculture (USDA).14 residues in tea samples from India, found that nearly 94% of the tea samples tested in India contained at least one of 34 different pesti- Degree of Contamination with Pesticide Residues cides, while over half contained a toxic cocktail of more than 10 dif- Over the past few years, numerous reports have been published ferent pesticides.20 The report relied on tests of 49 branded and pack- that point to high levels of toxic and illegal pesticide residues con- aged teas. Eight of the top 11 companies that make up a large part of taminating popular tea brands, underscoring the consequences of the tea market in India were represented, including Hindustan Uni- weak regulations and lack of proper enforcement in countries like lever Limited, a subsidiary of the global multinational company Uni- India and China that export a large proportion of tea that ends up in lever. Popular brands included in the study are Twinings and Lipton. the U.S. The presence of these pesticide residues in tea highlights a litany of problems within the industry, with broad implications for The residues found include DDT, which has been banned for use in the safety of imported food and the adequacy of U.S. enforcement agriculture in India since 1989, and , which was banned against hazardous and violative pesticide residues in food. in India in 2011. Over half of the samples tested contained illegal residues –either those that are not approved for use in tea cultiva- Regulation of Pesticides in Tea in Exporting Countries tion or exceed allowed limits.21 In addition to registered pesticides Poor regulations and enforcement in exporting countries can that have been long banned from agricultural use in tea cultivation in contribute to higher levels of pesticide residues in tea leaves. De- India (DDT, and triazophos), also found were (i) suspected mutagens veloping countries often lack rigorous pesticide laws and training and neurotoxicants (), and (ii) associated resources for pesticide inspectors and users, and the rapid growth with the global decline in bee populations ( like thia- of their agricultural markets outstrip the ability of regulatory and cloprid and ). Some of the most frequently detected enforcement agencies to keep pesticide use in check.15 Many de- pesticides include thiamethoxam (78%), (73%),- acet veloping countries, without internationally sponsored programs, amiprid (67%), (67%), DDT (67%), (67%), forego or limit such control programs and maintain the use of (61%), (61%), and monocrotophos (55%).22 older, non-patented, cheaper, more toxic, and environmentally persistent chemicals that can be manufactured within the coun- The Greenpeace India report also provides several concrete ex- try itself.16 While many of these chemicals have been banned in amples of tea with residues of pesticides that are not registered “western” countries, they are still freely available elsewhere.17 for use in India. According to the report, 68% of the 34 detected For example, in Vietnam, another major exporter, pesticide use pesticides were not registered at the time of publication for use

Not Just Pesticides – Other Contaminants Found in Tea

Heavy metal contamination in tea leaves has been docu- mented. Lead concentrations in Chinese tea were found in a study with 32% of samples exceeding the national maximum permissible concentration (MPC) of 2.0 mg/kg. An increasing trend in lead concentration on tea leaves was documented from 1989 to 2000. Proximity to highway and surface dust contamination was found to cause these elevated concentra- tions, as well as uptake of lead in soil by the roots of the tea plant.44 Up to 83% of teas have lead levels considered unsafe for consumption during pregnancy and lactation, as well as excessive levels of manganese and aluminum.45,46 Photo by André Karwath via Wikimedia

Page 10 Pesticides and You Vol. 35, No. 3 Fall 2015 A quarterly publication of Beyond Pesticides Disclosure of pesticides found in tea leaves in violative samples – what are they? Under FDA’s Pesticide Monitoring Program (PMP), imported samples, like that of tea, are collected at the point of entry into U.S. commerce. Illegal residues are defined as residues that are found at a level above EPA tolerance or FDA Action Levels (guideline levels for unavoidable residues of canceled pesticides that persist in the environment), or residues at a level of regulatory significance for which EPA has established no tolerance.

An analysis of the most recently published FDA data on residue levels in tea (black, green, and oolong) from 2008 to 2012 reveals a high rate of viola- tions. Out of the 65 samples of tea analyzed over these five years, nearly 30 percent had two or more illegal residues, with one sample from 2012 containing up to 14 violations. Of the 94 violations found in these samples, 76 were listed as “no registration” and 18 as “excess of tolerance.” Many of these violations are for pesticides that are currently used in U.S. agriculture, but lack a tolerance and presumably exposure data for use in tea, such as acetamiprid (a ), or permethrin (a pyrethroid). Other chemicals that were found to be in violation have been long banned from use in the U.S., including DDE (a DDT metabolite), carbendazim (MBC) (not allowed for use in agriculture),47 and heptachlor epoxide (a derivative of the pesticide heptachlor, which was banned in the U.S. for use in agriculture and home use due to its carcinogenicity and persistence in the environment).48

Violative Pesticides Found in Tea and Their Health Effects (Source: U.S. Food and Drug Administration, Pesticide Monitoring Program, 2008-2012) Pesticide Adverse Health Effects* 3-HYDROXYCARBOFURAN** Endocrine Disruptor, Reproductive/Developmental Effects, Possible Cholinesterase Inhibitor, Possible Neurotoxicant ACETAMIPRID (Insufficient Data) Endocrine Disrupter, Neurotoxicant, Possible Reproductive/Developmental Effects BIPHENYL Neurotoxicant Possible Reproductive/Developmental Effects CARBENDAZIM (MBC) Possible Carcinogen, Mutagen, Possible Endocrine Disrupter, Reproductive/Developmental Effects Possible Endocrine Disrupter, Reproductive/Developmental Effects, Cholinesterase Inhibitor, Neurotoxicant CYPERMETHRIN Possible Carcinogen, Possible Mutagen, Possible Reproductive/Developmental Effects DCPA (CHLORTHAL-DIMETHYL) Possible Carcinogen, Possible Reproductive/Developmental Effects DDE, P,P’- (DDT) Carcinogen, Mutagen, Endocrine Disruptor, Cholinesterase Inhibitor, Possible Neurotoxicant DICOFOL Possible Carcinogen, Possible Endocrine Disrupter, Neurotoxicant DIFENOCONAZOLE Carcinogen, Possible Reproductive/Developmental Effects Possible Reproductive/Developmental Effects FENHEXAMID Possible Endocrine Disrupter (Insufficient Data) Endocrine Disrupter, Possible Neurotoxicant FLONICAMID Possible Carcinogen, Reproductive/Developmental Effects FLUCYTHRINATE Possible Reproductive/Developmental Effects, Neurotoxicant FLUDIOXONIL Possible Carcinogen, Possible Reproductive/Developmental Effects Possible Carcinogen, Endocrine Disrupter, Possible Reproductive/Developmental Effects HEPTACHLOR EPOXIDE Carcinogen, Possible Endocrine Disruptor, Reproductive/Developmental Effects, Neurotoxicant (HEPTACHLOR) IMIDACLOPRID Mutagen, Possible Reproductive/Developmental Effects, Possible Neurotoxicant LAMBDA- Possible Reproductive/Developmental Effects, Possible Neurotoxicant Cholinesterase Inhibitor, Neurotoxicant PERMETHRIN Possible Carcinogen, Endocrine Disruptor, Reproductive/Developmental Effects, Possible Cholinesterase Inhibitor, Neurotoxicant Cholinesterase Inhibitor, Neurotoxicant Possible Carcinogen, Endocrine Disruptor, Reproductive/Developmental Effects, Neurotoxicant TEBUCONAZOLE Possible Carcinogen, Reproductive/Developmental Effects TRIAZOPHOS Cholinesterase Inhibitor, Neurotoxicant *These pesticides focus solely on those in violation of U.S. law, and thus represent only a small percentage of all pesticides found in U.S. tea imports, which result in human exposure. ** Health effects of parent chemical

Vol. 35, No. 3 Fall 2015 Pesticides and You Page 11 A quarterly publication of Beyond Pesticides on tea by the CIBRC (Central Insecticides Board and Registration , is not approved for use on tea crops, either.25 Triazophos is Committee), although some appeared on lists of pesticides recom- also a WHO Class Ib pesticide that is not approved for use on tea in mended for use on tea at the state level, indicating inconsistencies India, although it is registered.26 in regulations or recommendations at the regional and national levels. Of the neonicotinoid insecticides detected in the samples, Rampant contamination of tea leaves with pesticides has also only thiacloprid and thiamethoxam are registered for use on tea been found in China. In April 2012, Greenpeace China released a production in India.23 Two neonicotinoids, acetamiprid and imida- report, Pesticides: Hidden Ingredients in Chinese Tea, which found cloprid, not approved for use in tea cultivation, are among the evidence of pesticide residues in popular tea brands. The report most commonly found residues in the report. Other illegal pesti- found that all of the 18 samples tested had traces of at least three cide residues detected include the insecticide , a pyr- different pesticides.27 In total, 29 different pesticides were de- azole miticide/insecticide, which is not registered for use in India.24 tected, including reproductive and developmental toxicants (car- Endosulfan was found in about 8% of tea samples in the Greenpeace bendazim, benomyl, myclobutanil, and flusilazole) and bee-killing India investigation, despite being banned for production, use, and sale chemicals (imidacloprid and acetamiprid).28 Twelve of the samples throughout India following a 2011 Supreme Court decision, although had traces of pesticides banned for use on tea by China’s Ministry the chemical is still registered for use by CIBRC. of Agriculture (including and fenvalerate).29 Six samples contained a mix of over 10 pesticides, with one sample containing Other unapproved pesticides found in the report include monocro- up to 17 different pesticides.30 tophos, classified by the World Health Organization (WHO) as a Class Ib (highly hazardous) pesticide that has not been registered for use in U.S. Regulations of Tea Imports: tea production at the government level due to its WHO designation. High Violations and Little Monitoring , found in two samples, is another WHO Class Ib pes- With the exception of meat, poultry, and certain egg products, for ticide and is not registered in India for any use; its parent compound, which USDA is responsible, FDA is charged with enforcing EPA toler-

Import Tolerances on Tea –A Closer Look at Endosulfan According to EPA, when no U.S. registration for a pesticide exists for a specific commodity, interested persons may submit a petition request- ing that EPA establish an import tolerance (or tolerance exemption) for a pesticide residue on a food or feed commodity, which will allow the food or feed treated with the pesticide in foreign countries to be lawfully imported into the U.S.49 The term “import tolerance” is used as a convenience to refer to a tolerance that exists in the U.S. for which there is no accompanying U.S. registration, but that meets U.S. food safety standards.50 According to the Global Maximum Residue Limits Database and the Code of Federal Regulations, tea leaves are shown to have 21 pesticide tolerances, of which 11 are import tolerances.51,52 This is not surprising for a commodity like tea, which is largely imported due to lack of domestic commercial output, but allows for a way in which consumers can be exposed to pesticides that are otherwise not allowed for use in the U.S. Although requesting an import tolerance requires data on product chemistry, residue chemistry, and toxicology so that EPA can assess potential dietary risk and make the required acceptable risk finding, the agency does not require data on worker exposure, residential exposure, or environmental fate and effects, which are required if the pesticide were registered for use in the U.S.53

In 2010, EPA proposed to phase out all tolerances for endosulfan during the period 2012 to 2016 based on use, as it “can pose unacceptable neurological and reproductive risks to farmworkers and wildlife and can persist in the environment.”54 However, in 2013, EPA allowed residues of the cancer-causing insecticide endosulfan on imported Chinese teas until July 31, 2016, in order to provide “additional time to transition to an alternative to endosulfan” and raising serious concerns of further exposure to the toxic carcinogen for farmworkers and consumers.55 The agency proposed a transition time that would allow growers time to adopt alternatives, with the last four uses ending on July 31, 2016.56 For tea, EPA proposed an immediate revocation, since there is little, if any, endosulfan used in tea production in the U.S.57 However, the Chamber of Commerce of the Zhejiang International Tea Industry filed a complaint indicating that it would need five years or less to find feasible alternatives to endosulfan.58 It also indicated that it was unable to provide comment on the tolerance revocation ruling since EPA did not provide proper notice to the World Trade Organization.59 In acknowledging this oversight, EPA now allows endosulfan residues of 24 parts per million (ppm) in imported Chinese tea until July 31, 2016.60 Despite the risks posed by endosulfan residues, EPA sees the decision as “appropriate,” raising ques- tions of whether EPA is putting economic interests ahead of public health.61

Page 12 Pesticides and You Vol. 35, No. 3 Fall 2015 A quarterly publication of Beyond Pesticides A Closer Look into Current Efforts in Tea Sustainability: Rainforest Alliance Certification

The Rainforest Alliance Certified™ (RAC) seal, a little green frog, is found on tea and other products around the world and asserts a certain level of sustainability that aims to protect workers and their families, as well as wildlife and habitat. It does not meet organic standards in prohibiting all hazardous pesticide uses. As of 2012, Rainforest Alliance outpaced organic and Fairtrade certification in countries like Kenya and India (unlike China, in which most of the compliant production was organic certified).62 RAC standards are set by a coalition of non-profit conservation organizations all over the world, known as the Sustainable Agriculture Network (SAN).

RAC’s Sustainable Agriculture Standard includes pesticide use criteria.63 The standards address worker safety through measures such as education of pesticide labels, storage, protective equipment, and restricted entry intervals. If a consumer is looking to avoid exposure to pesticides in their tea, however, RAC does not ensure that a labeled product is free of residues. Unlike organic agriculture, which adheres to a default prohibition of synthetic fertilizers and pesticides, which are subject to the National List of Allowed and Prohibited Substances review, SAN’s standards allow for the use of some agrochemicals that fall outside the approved organic list.

Certain toxic pesticides are prohibited from use under RAC’s “critical criteria,” including: • Substances – biological, organic, or agrochemical – that are not legally registered for use in the country. • Agrochemicals on the List of Banned or Severely Restricted Pesticides in the U.S. by EPA or banned or severely restricted in the European Union. • Substances banned globally under the Stockholm Convention on Persistent Organic Pollutants (POPs). • Substances listed in Annex III of the Rotterdam Convention on Prior Informed Consent (PIC). • All Pesticide Action Network Dirty Dozen substances.

The farm may have a plan for eliminating the use of World Health Organization (WHO) Class Ia (Extremely Hazardous) and Ib (Highly Hazardous) technical grade active ingre- dients of pesticides and for “reducing the use” of WHO Class II (Moderately Hazardous) technical grade active ingredients. (The farm may choose not to incorporate this criterion as part of RAC’s 80% compliance requirement for “applicable criteria.”) Farms that comply with this criterion must demonstrate that there are no viable alternatives that exist for a type of pest or infestation, the pest or infestation has or would have resulted in significant economic damage, and measures must be taken to substitute these WHO ClassI a, Ib, and II technical grade active ingredients of pesticides. Additionally, farms must “take steps to avoid introducing, cultivating, or processing” transgenic crops.64 ances for imported foods (as well as domestically produced foods Over these five years, tea appeared on this list in 2008 with a 23% shipped in interstate commerce). Due to resource constraints and violation rate,35 and again in 2011 with a 26.7% violation rate.36 In the sheer volume of U.S. imports, FDA is unable to inspect and test FDA’s most recent report for 2012, oolong tea was found to have for pesticide residues on all imported foods, using certain tools to al- a 100% violation rate, and an overall 50% violation rate for all tea low for a more targeted approach. These tools include an automated samples analyzed.37 While the sample sizes in FDA’s analyses are screening system called PREDICT (Predictive Risk-based Evaluation for small, they highlight a persistent problem regarding tea imports – Dynamic Import Compliance Targeting), which utilizes data such as in- imported tea samples contain pesticide residue higher than estab- herent product risk ratings and results of facility inspections to assign lished tolerances or for which no tolerance has been established, a risk score that informs the agency whether a physical examination putting American consumers at risk. of the product is warranted.31,32,33 FDA may issue import alerts, which can result in “detention without physical examination” (DWPE) and There is evidence that FDA’s approach to monitoring imported food is refusal of subsequent shipments from the importer.34 insufficient. A 2014 GAO Report, Food Safety: FDA and USDA Should Strengthen Pesticide Residue Monitoring Programs and Further Dis- According to reports from FDA’s Pesticide Monitoring Program close Monitoring Limitations, criticizes FDA for not testing for several (PMP), which analyzes and reports on pesticide residue levels in commonly used pesticides with established tolerance levels, such as imported and domestic food, tea has been listed multiple times the herbicides glyphosate and 2,4-D, as well as not using statistically over the past five years as an import commodity that “may war- valid methods consistent with the Office of Management and Budget rant special attention,” a designation that is triggered forcom- (OMB) to collect information on incidence and level of pesticide resi- modities with (i) at least 20 samples analyzed or with a minimum dues. In 1993, FDA analyzed over 12,000 domestic and imported food of three violations, and (ii) a violation rate of 10 percent or higher. samples for pesticide residues, but this number was reduced to a low

Vol. 35, No. 3 Fall 2015 Pesticides and You Page 13 A quarterly publication of Beyond Pesticides of 5,000 in 2008. The report states that FDA now tests less than one- international food standards).40 The reduction of pesticide use tenth of one percent of all imported fruits and vegetables, equating should be accomplished on both sides of the import/export equa- to about one test out of tion. Importing coun- every 2,100 entry lines.38 tries like the U.S. and This has major implica- EU, must continue to tions for tea because it is monitor imports and re- primarily imported into duce Maximum Residue the U.S. A 1987 GAO re- Limits (MRL) and toler- port, Federal Regulation of ance levels for hazard- Pesticide Residues in Food, ous pesticides. Exporting points to a historic inade- countries like China and quacy in FDA’s approach to India can maintain their monitoring imported food, economic edge in the singling out the agency’s tea industry by imple- inability to prevent adul- menting stronger regu- terated foods from reach- lations and enforcement ing the marketplace.39 of pesticide use and by Photo by Haneburger via Wikimedia. bolstering their organic The results of FDA’s PMP, tea output.41 and the agency’s conclusion that pesticide residue levels are “gen- erally in compliance” with EPA’s permitted uses and tolerances, Other efforts to increase sustainability include standards developed by are not derived from comprehensive evidence and statistically organizations including Fairtrade International, IFOAM Organic Interna- valid methods. The inadequacies suggest that these violation tional (formerly International Federation of Organic Agriculture Move- rates could be severely underreported and highlight major short- ments), and Rainforest Alliance (see box), the Ethical Tea Partnership comings in FDA’s approach to the monitoring of pesticides on im- (ETP), and UTZ Certified, which together have certified or verified 12 ported produce. percent of global tea production as of 2011/2012.42 According to the In- ternational Institute for Sustainable Development, one-third of produc- A 2010 report from the National Academies of Sciences, titled En- tion is subject to voluntary sustainability standards on the international hancing Food Safety: The Role of the Food and Drug Administra- market (or 4% of global tea production and 9% of exports).43 tion, highlights limitations in FDA’s domestic and imported food programs. For example, foreign producers may have trouble under- Conclusion standing or even accessing FDA requirements or may be unable to The presence of pesticide residues in tea leaves may undermine access EPA-approved pesticides. Additionally, when FDA takes ac- the popular beverage’s status as a health tonic. The U.S. primarily tion on import shipments, communication of the action may not imports its tea from China, India, and Sri Lanka, where regulations occur within the country or to other countries. on pesticide use, worker protection, and environmental contami- nation oftentimes do not measure up to U.S. and international The international bodies seeking harmonization of standards for standards. Additionally, FDA’s failure to properly monitor imports, pesticide residues are not working to ensure adequate protection including that of tea, means that certain illegal pesticides are end- of consumers and farmworkers. Standards, such as those in the ing up in the food supply of U.S. consumers. Given these prob- European Union (EU), have allowable levels that are often lower lems, consumers should choose products certified and labeled than many countries, including the Codex Alimentarius (created organic, which prohibits the pesticides that are found in residue by the Food and Agriculture Organization [FAO] and the World surveys and verifies that growers are in compliance with organic Health Organization of the United Nations to develop harmonized systems management plans and allowed substances.

Page 14 Pesticides and You Vol. 35, No. 3 Fall 2015 A quarterly publication of Beyond Pesticides Endnotes

1. U.S. Environmental Protection Agency. (2013, February). Endosulfan; image/2014/cocktail/download/TroubleBrewing.pdf Pesticide Tolerance. (EPA-HQ-OPP-2011-0104; FRL-9363-1). Retrieved from 21. Greenpeace India. (2014). Trouble Brewing: Pesticide residues in tea samples http://www.gpo.gov/fdsys/pkg/FR-2013-02-06/html/2013-02392.htm from India. Retrieved from http://www.greenpeace.org/india/Global/india/ 2. Greenpeace India. (2014). Trouble Brewing: Pesticide residues in tea samples image/2014/cocktail/download/TroubleBrewing.pdf from India. Retrieved from http://www.greenpeace.org/india/Global/india/ 22. Greenpeace India. (2014). Trouble Brewing: Pesticide residues in tea samples image/2014/cocktail/download/TroubleBrewing.pdf from India. Retrieved from http://www.greenpeace.org/india/Global/india/ 3. Greenpeace China. (2012). Pesticides: Hidden Ingredients in Chinese Tea. image/2014/cocktail/download/TroubleBrewing.pdf Retrieved from http://www.greenpeace.org/eastasia/Global/eastasia/ 23. Greenpeace India. (2014). Trouble Brewing: Pesticide residues in tea samples publications/reports/food-agriculture/2012/Pesticide%20Hidden%20 from India. Retrieved from http://www.greenpeace.org/india/Global/india/ Ingredient%20Report%20Final.pdf image/2014/cocktail/download/TroubleBrewing.pdf 4. U.S. Environmental Protection Agency. (1992). R.E.D. Facts: Heptachlor. 24. Greenpeace India. (2014). Trouble Brewing: Pesticide residues in tea samples (738-F-92-002). Retrieved from http://www3.epa.gov/pesticides/chem_ from India. Retrieved from http://www.greenpeace.org/india/Global/india/ search/reg_actions/reregistration/fs_PC-044801_1-Mar-92.pdf image/2014/cocktail/download/TroubleBrewing.pdf 5. U.S. Environmental Protection Agency. (2002, March). Pesticide Fact Sheet: 25. Greenpeace India. (2014). Trouble Brewing: Pesticide residues in tea samples Acetamiprid. Retrieved from: http://www3.epa.gov/pesticides/chem_ from India. Retrieved from http://www.greenpeace.org/india/Global/india/ search/reg_actions/registration/fs_PC-099050_15-Mar-02.pdf image/2014/cocktail/download/TroubleBrewing.pdf 6. U.S Food and Drug Administration. (2008-2012). Pesticide Monitoring 26. Greenpeace India. (2014). Trouble Brewing: Pesticide residues in tea samples Program Reports [Excel]. Available at http://www.fda.gov/Food/ from India. Retrieved from http://www.greenpeace.org/india/Global/india/ FoodborneIllnessContaminants/Pesticides/ucm2006797.htm image/2014/cocktail/download/TroubleBrewing.pdf 7. U.S. Government Accountability Office. (2014). FDA and USDA Should 27. Greenpeace China. (2012). Pesticides: Hidden Ingredients in Chinese Tea. Strengthen Pesticide Residue Monitoring Programs and Further Disclose Retrieved from http://www.greenpeace.org/eastasia/Global/eastasia/ Monitoring Limitations. 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Retrieved from http://www.ncbi.nlm.nih.gov/ Food/FoodborneIllnessContaminants/Pesticides/UCM382443.pdf pubmed/11246121 37. U.S. Food and Drug Administration. (2015). Pesticide Monitoring Program: 18. Chang, K. (2015). World tea production and trade: Current and future 2012 Pesticide Report. Retrieved from http://www.fda.gov/downloads/ development. Rome, Italy. Retrieved from http://www.fao.org/3/a-i4480e. Food/FoodborneIllnessContaminants/Pesticides/UCM432758.pdf pdf 38. U.S. Government Accountability Office. (2014). FDA and USDA Should 19. Phung, D. T., Connell, D., Miller, G., Rutherford, S., & C. Chu. (2012). Pesticide Strengthen Pesticide Residue Monitoring Programs and Further Disclose regulations and farm worker safety: the need to improve pesticide regulations Monitoring Limitations. (GAO-15-38). Retrieved from http://cooklibrary. in Viet Nam. 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40. Food and Agriculture Organization of the United Nations. (2014). Committee 51. Global MRL Database. (2015). Retrieved from https://www.globalmrl.com/ on Commodity Problems, Intergovernmental Group on Tea: Implications of db#query Maximum Residue Levels of Tea on Trade. Bandung, Indonesia. Retrieved 52. Electronic Code of Federal Regulations. (2015). Retrieved from http://www. from http://www.fao.org/fileadmin/templates/est/meetings/IGGtea21/14- ecfr.gov/cgi-bin/ECFR?page=browse 3-MRLsImplicationTrade__2_.pdf 53. U.S. Environmental Protection Agency. (2005). NAFTA Guidance Document 41. Food and Agriculture Organization of the United Nations. (2014). Committee on Data Requirements for Tolerances on Imported Commodities in the on Commodity Problems, Intergovernmental Group on Tea: Implications of United States and Canada. Retrieved from http://www.epa.gov/oppfead1/ Maximum Residue Levels of Tea on Trade. Bandung, Indonesia. 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